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Policy and practice on avoidance of conflict metals

Criteria: This criterion expects companies to take the following steps to resolve the conflict minerals problem; trace from where the minerals used in their products are sourced, audit their supply chain, and support legislation that incentivizes the sourcing of minerals in regions where conflict is not escalated due to mineral sourcing. Reasonable timelines are needed to successfully achieve these actions.

Status: This is a new criterion. So no prior information collated or available. The Global e-Sustainability Initiative (GeSI) and Electronic Industry Citizenship Coalition (EICC) - launched their Conflict-Free Smelter (CFS) program, as part of industry's efforts in response to the conflict minerals provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The minerals covered in the law - coltan (columbite-tantalite, a source of tantalum), cassiterite (tin), wolframite (tungsten) and gold - are used in various industrial, consumer and electronics products and the CFS program focuses on tantalum and tin. Nearly one year after it was signed into law the conflict minerals provision has failed to be enacted. However the voluntary initiative of the Industry continues and as a responsible manufacturer of ecosafe electronics products HCL will proactively advocate our supply chain on the practice of avoidance of conflict metals.

Action Plan: HCL is committed to make their supply chains conflict-free, and more transparent in the process. However the delay in implementation of the rule and the fact that sourcers of these minerals are 4-5 level below in the supply chain makes the process of auditing our mineral procurement organizations a time consuming process.We are in the process of working with these levels to receive the information on their mineral procurement policy. This is a work in progress and as soon as we receive information we shall take action accordingly.


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